CMS Leaves ICD-10 Testing Up to the Industry

The Centers for Medicare & Medicaid Services (CMS) announced in April it will not perform end-to-end tests of ICD-10-CM and PCS fee-for-service (FFS) claims with providers before October 2014. This means providers, facilities, and EMR vendors must make sure they are ready for the mandatory implementation.

The federal agency explains end-to-end testing was already done when its 5010 data standard was implemented last year, and ICD-10-CM and PCS are code sets rather than mechanisms to manage the data. CMS says providers and payers are pretty much on their own to assure ICD-10 codes will be reportable and payable. End-to-end testing is a process-wide testing of electronic claims submission, adjudication, and “payment” to iron out bugs before a change is made to Medicare and commercial payment.

The agency is doing internal testing, but it won’t be providing a lot of support to providers, Rhonda Buckholtz,CPC, CPMA, CPC-I, CRC, CDEO, CHPSE, CENTC, COBGC, CPEDC, CGSC, vice president of ICD-10 education for AAPC, explained. She said this presents a challenge to both providers, who must assure their systems can handle ICD-10-related claims, and payers, who must retool and test their systems in time for the transition. The biggest worry is guaranteeing the process works from provider to payer and back.

Medicare administrative contractors (MACs) are encouraging providers to begin testing, but also won’t be providing much support. Lack of a cohesive national effort means chaos, Buckholtz fears. “We can’t have another 5010,” she said, referring to the delayed and confusing implementation of the data standard now used for Medicare and commercial claims. She and others in the industry are working to change CMS’ mind before it becomes too late. Buckholtz said, “this is not just a technology issue, it’s how that code actually hits systems and if it can get paid.”

In the meantime, she advises, providers should communicate with their electronic health care system vendors and payers to assure claims and revenue will not be held up by systems not ready for the new code set’s implementation.